ML20154J674

New England Coalition on Nuclear Pollution Answers to Applicant First Set of Interrogatories & First Request for Production of Documents to All Parties & Participating Local Govts Re Seabrook....* W/Svc List.Related Correspondence

ML20154J674
Person / Time
Site:	Seabrook
Issue date:	09/16/1988
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
CON-#388-7112 OL, NUDOCS 8809230105
Download: ML20154J674 (5)

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RELATED CORnESPONDENCI September 16, 1988 000KEIED UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 'aB MP 21 P4 :22

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In the Matter of )

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6F g Igg g Bi t.lica Public Service Company of )

New Hampshire, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (SeCirook Station, Units 1 & 2) ) OFFSITE EMERGENCY

) PLANNING

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NECNP'S ANSWERS TO APPLICANTS' FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENT TO ALL PARTIES AND PARTICIPATING LOCAL GOVERNMENTS REGARDING THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITI~ES The New England Coalition on Nuclear Pollution ("NECNP")

hereby responds to Applicants' First, Set of Interrogatories and First Request for the Production of Documents, etc., on the Seabrook Plan for the Massachusetts Communities ( "S PMC",) .

1) Please identify the person (s) answering or substan-tially contributing to the answer to each of the following interrogatories.

ANSWER: Diano Curran

2) Please identify and produce all documents, and describe i in detail all conversations not otherwise reflected in such documents, which reflect or refer to what actions any Massa-chusetts state or local government entity or official would, could, might, would not, could not, or might not take in the event of an actual radiological emergency at Seabrook Sta-tion.  !

ANSWER: NECNP objects to this interrogatory because it is vague ,

and over-broad. Without waiving the objection, NECNP states that h$k $DO f[

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O it does not possess any such documents, nor it is privy to any such conversations.1

3) Please identify and produce all documents, and describe 1 in detail all conversations not otherwise reflected in such I documents, which reflect, refer to, or relate in any way to any action by any Massachusetts state or local government official or entity to block, hinder or delay the licensing of Seabrook Station.

ANSWER: NECNP objects that this interrogatory is irrelevant to the litigation at hand. Withcut waivin-, the objection, NECNP states that it does not possess any such documents, nor it is privy to any such conversations.

4) Please identify and produce all documents generated after January 1, 1980, that reflect or refer to any emer-gency planning (other than that engaged in by Applicants) conducted or contemplated for the Massachusetts EPZ or any portion thereof, including but not limited to emergency planning required pursuant to the Emergency Planning Act.

Such documents should include, but not be limited to, docu-ments that reflect or refer to whether the SPMC or any other plan for dealing with a radiological emergency at Seabrook Station has or has not been, or will or will not be, used in planning for emergency situations other than those involving Seabro0X Station.

ANSWER: NECNP does not possess any such documents.

5) Please list every admitted SPMC contention which you do not intend to participate in litigating, i.e., concerning l which you will not take discovery, present evidence, make <

arguments, conduct cross-oxamination, or submit proposed f:indings.

1 It should be noted with respect to all document requests that NECNP does not includo in its answers any documents that have already boon filed with the Licensing Board and sorved on '

the parties to this proceeding.

o ANSWER: At this time, NECNP intends to litigate all of the admitted contentions.

6) For every admitted SPMC contention that you submitted and do not hereby withdraw, and for every other admitted SPMC contention that you did not list in response to Inter-rogatory 5 above, individually for each such contention please:

(a) State in detail all the facts underlying each assertion contained in the contention.

ANSWER: The contentions sponsored by NECNP are based entirely in the facts that are alleged in the bases of those contentions, and on the documents that are cited in those contentions. As for contentions submitted by other parties, NECNP relies on the fac-tual information contained in those contentions and the documents cited therein, and is not aware of other facts or documents that may have been used to support them.

(b) State the source of each such fact. If the source is the personal knowledge of one or more persons, identify the person (s). If the source is one or more documents, identify and produce the document (s).

ANSWER: The sources of the facts contained in NECNP's conton-j tions are the documents cited therein. NECNP does not know the sources of other contentions, other than what is stated in their

! bases.

(c) Identify any expert witness who is to testify con-cerning the contention, and state the substance of the facts, opinions. and grounds for opinions to which the expert is expected to testify.

I j ANSWER: NECNP has not yet chosen expert witnesses for this liti-t gation. This answer will be updated if and when such experts are identified.

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(d) Identify any non-expert witness who is to testify concerning the contention, and state the substance of the facts to which the witness is expected to testify.

ANSWER: NECNP has not yet chosen non-expert witnesses for this litigation. This answer will be updated if and when such experts are identified.

(e) Identify and produce any documents which reflect or refer to any type of study, calculation or analysis bearing upon the substance of the contention.

ANSWER: NECNP possesses no such documents.

Respectfully submitted, D'

Di./ M ane Curran HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500 .

September 16, 1988 CERTIFICATE OF SERVICE I certify that on September 16, 1988, copies of this plead-ing were served by first-class mail on the parties to the attached service list, and that a copy was also sent to Applicants by telecopier.

Diane curran

, , SEABROOK SERVICE LIST Offsite Licensing Board Stanley W. Knowles Matthew T. Brock, Esq.

Ivan W. Smith, Chairman Board of Selectmen Shaines & McEachern NN iif .

Atomic Safety and ucensing Board P.O. Box 710 P.O. Box 360 'aNFC US Nuclear Regulatory Commission North flampton, Nil 03826 Maplewood Awnue Washington, D.C 20555 Portsmouth,NH 03801 J.P. Ndeau Dr. Jerry Harbour Town of Rye Sandre Gavutis 18 SEP 21 P4 :22 Atomic Safety and ucensing Board 155 Washington Road RFD 1, Box 1154 i US Nuclear Regulatory Commission Rye,Newflampshire 03870 East Kensington,NH 03827 g- , 3; , , , , , ,

Wcshington, D.C 20555 gg g,y;y, W g i Senator Gordon J. Ilumphrey Robert A. Backus, Esq. gp y,g '

Gustaw unenberger U.S. Senate Deckus, Meyer & Solomon

Atomic Safety and ucensing Board Washington, D.C 20510 1111mell Street US Nuclear Regulatory Commission (Attn. Tom Bureek) Manchester NH 03105 ,

a Wsshington D.C 20555 Richard A. llampe, Faq. Sherwin E. Turk, E.q.

Atomic Safety and ucensing flampe and McNicholas Office of General Counsel Decrd Panel 35 Pleasant Street US Nuclear Regulatory Commission U1 Nuclear Regulatory Commission Concord, Nil 03301 Washington, D.C 20555 i Washington, D.C 20555 (

Ga ry W. llolmes, Esq. II. Joseph Flynn, Esq.

Dccketing and Sersice Branch llotmes & Dlis Office of Genere! Counsel g I US Nuclear Regulatory Commission 47 Winnacunnent Road TEMA Washington, D.C 20555 llampton, Nil 03842 500 C Street S.W.

Washington, D.C 20472 Mrs. Anne E. Goodman William Armstrong I

l Doard of Selectmen Chil Defense Diractor Ocorge Dana Bisbee, Esq.

1315 New Market Road 10 Front Street Geoffrey M. lluntington, Esq.

l Durham, Nil 03842 Exeter, Nil 03833 Office of the Attomey General

State llouse Annes ,

, Wilhtm S. Lord, Selectman Cama A.Canney Concord,MI 03301 [

] Toms Itall- Friend Street City Manager i Arnecury,MA 01913 City 11:11 R. Scott Ilill.Whilton I 126 Daniel Street Lagovhs, Da rk, Ilill.Whilton i Jane Doughty Portsmouth, MI 03801 and McGuire I l

SAPI. 79 State Street l l 5 Market Street Edusrd A. Thomas Newburyport,MA 01950 Q:srsouth, Ml OM01 IT.MA j 482 J.W. McCormack (POCll) Diana Sidebotham .

I Senator Gordon J. Ilumphrey Doston,MA 02109 RfD # 2 Box 12/4  !

l 1 Eagle Square, Ste 507 Putney,VT 05346 a Concord,MI 03301 Charles P. Graham, Esq.

i McKay, Murphy and Oraham Richard Donovan I i Michael Santosuceso, Chairman 100 Main Street FEMA f 1 Doord of Selectmen Amesbury,MA 01913 482 J.W. M4ormack (POCll) l Jestil Street, RTD # 2 Doston,MA 02109

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i South llampton, Nil OM42 Alfred V Sargent, Chairman I l Board of Selectmen }

Judith II. Mizner, Esq. Toen of Salisbury, MA 01950 i Sihtrgiate, Genaet, et at  :

88 Ilroad Street Rep. Rceerta C Pewar [

l Ikxten,MA 02110 Dnnkuster Road i flampton rafts,MI 0244 i Thomas O. Dignan, Esq. [

R K. Gad II, Esq. Phillip Ahrens, req. t Ropes & Grey Assistant Attorney General I

215 Franklin Street State llouse, Stanon #6  !

l Dexton,MA 02110 Augusta,ME 04333 r

! Cstol S. Sneider, Esquire Allee 14m;=rt j j Assistant Attorney General CMI Defense Director 1 Ashbunon Place,19th Ihr [

! Toms of Brentomto!

l Ik= ton, MA 02108 Eseter.Mi 03833 I i l  !

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